McGuire v. Almy
Supreme Court of MA - 1937
- D was an insane person; P was D's caretaker.
- D became violent and dangerous while locked in her room one day.
- Upon entering the room P saw D was holding a chair by the leg as if she were going to strike someone. P attempted to remove the chair from her hand, but D managed to strike her causing injuries.
- P sued D in battery.
- Lower court directed a verdict in favor of D.
- MA Supreme Court reversed, found for P.
- Is an insane individual who is capable of forming the intent to strike another and acts upon that intent liable to the individual for injuries suffered?
- An insane individual who is capable of forming the intent to strike another and acts upon that intent is liable to the individual for injuries suffered.
- The law today, for the most part, holds insane people liable for the torts they commit. No distinction is made as to the liability of insane people for intentional and negligent torts.
- An insane person who by his act does intentional damage to the person or property of another is liable for the damage to the same extent as a normal person would be.
- The role of fault does not need to be considered in this case.
- The jury could have found the D was capable of entertaining and did entertain an intent to strike and injure the P and that she acted with that intent.
- The requisite intent necessary to hold someone liable for intentional torts does not require that the D's purpose be malicious or harmful. D only needs to intend the act or consequence.
- It is not required that the D had the mental capacity to recognize and appreciate the danger of hitting someone with a chair.